Privacy Policy and Cookie Notice

 

  1. What is this document about?

This cookie and privacy policy covers your use of the Agate service, which is a digital service that allows you to pay for premium articles via your Agate account. We are Agate Systems Limited: we are what’s termed the “data controller” for personal data that is collected by the Agate service. Agate Systems Limited is a company registered in England and Wales, with company registration number 10169880.

 

This privacy policy sets out what data we collect from you, what we do with it, with whom we share it, how you can manage the data you give us, and what to do if you want to make a complaint.

 

  1. What information do we collect from you?

2.1        Registration

The minimum information we need to register you is your name, email address, post code and a password.

 

2.2        Collection of information

(a)         We collect data from registered users in order to:

(i)          To provide the Agate services to users.

(ii)        To help us to monitor and improve the services we offer.

(iii)       If we have permission from you, to market services to you.

(b)         We collect information on you:

(i)          when you register for an Agate wallet

(ii)        when you use the Agate service

(iii)       through cookies

We need to have a legal reason to use your information .  These reasons can be because we have a contract with you, or we have a legal duty to do so, we have a legitimate interest to do so, or we have your consent. Wehave listed our uses and their corresponding reasons below

 

How we use your information Our legal reasons
To provide the Agate service to you To fulfill our contract with you
Our legitimate interests
Sharing subscription data with the publisher which has the subscription To fulfill our contract with you
Our legitimate interests
Your consent
To track usage and perform analytics Our legitimate interests

If we base our use of data on a legitimate interest, we will first carry out an analysis. We will consider issues like what are the benefits of the use of the data, how important those benefits are, what the impact of not using the data would be, how intrusive the use would be, and whether its reasonable.

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

  1. Cookies

When you use the Agate service, the service can store cookies on your computer. Cookies are little pieces of information that can help identify your browser and that can store information, e.g. application settings. Agate uses cookies to track your usage, to know when you to charge you or not charge you for articles, to track and list articles that you have been charged for and/or read at no charge, to keep you logged in, to improve ease-of-use and the overall user experience.

 

  1. How we use and share your information

After you have registered, and with your permission, we may send you emails we think may interest you. Newsletters may be personalised based on what you have been accessing through the Agate Service. At any time you can decide not to receive these emails and will be able to ‘unsubscribe’.

We may share subscriber data with a publisher to ensure that you are able to continue to enjoy a subscription you have with that subscriber.

We will not share your details with third parties for marketing purposes, unless you have given permission. In that case, we may advertise publisher services to you as part of our regular marketing communications to you, however this will be sent and managed by us or our service providers – your data will not be passed on to the publishers.

We can access and release personal information to comply with relevant laws and government requests, to operate our systems properly and to protect both us and our users.

Any other organisations who access your information in the course of providing services on our behalf will be governed by strict contractual restrictions to make sure that they protect your information and keep to data-protection and privacy laws which apply. We may also independently audit these service providers to make sure that they meet our standards. We may use service providers to help us run these sites (or services available on the sites), some of whom may be based outside the EEA.

We protect your data by using appropriate security measures.

 

  1. Google Analytics

We use Google Analytics on our sites and services for anonymous reporting of site usage. If you would like to opt-out of Google Analytics monitoring your behaviour on our sites please use this link (https://tools.google.com/dlpage/gaoptout/)

 

  1. Newsletter

If we have a newsletter or similar communication with you, we may use a third party provider, MailChimp, to deliver that communication. We will gather statistics around email opening and clicks using industry standard technologies including clear gifs, to help us monitor and improve our newsletter.

 

  1. Online customer contacts

We collect feedback, queries and complaints submitted by users using an online customer services tool hosted by Zendesk. This company is a data processor for Agate Systems and only processes personal information in line with our instructions.

 

  1. WordPress

We use a third party service, WordPress.com, to publish the Agate website and to host certain pages of your Account page (for instance this Privacy Policy). These sites are hosted at WordPress.com, which is run by Automattic Inc. We use a standard WordPress service to collect anonymous information about users’ activity on the site, for example the number of users viewing pages on the site, to monitor and report on the effectiveness of the site and help us improve it. WordPress requires visitors that want to post a comment to enter a name and email address. For more information about how WordPress processes data, please see Automattic’s privacy notice.

 

  1. Social Media

If you send us a private or direct message via social media the message will be stored for a period of time depending on the social media tool used. We will process your data in order to respond to that message, and use the content of your message where appropriate to improve or maintain our service.

 

  1. If you email us

We will process your data in receiving and responding to any email you send to us.

 

  1. Updating your information

You can update your personal information at any time on your Account page. If we have marketing preferences, you will also be able to change your marketing preferences on that page. You can get to this page from settings menu located at the bottom of the Agate wallet. To open the Agate wallet, simply click on the green Agate tab that appears on the upper left hand side of any Agate-enabled page.

 

  1. Children’s Data

We do not knowingly store or use the data of people under the age of 16.

 

  1. Complaints

We will use your data to respond to and resolve any complaints that we receive from you. We will also compile statistics regarding the nature and number of complaints, but this will be done in a manner which anonymises the identity of the complainant.

We will keep information about complaints for as long as the complainant holds an Agate account, and then for a period of 6 months after the account is closed.

 

  1. Access to Personal Information

You can ask us what information we hold about you, by making a “subject access request”. If we do hold information about you we will:

  • give you a description of it;
  • tell you why we are holding it;
  • tell you who it could be disclosed to; and
  • let you have a copy of the information in an intelligible form.

If you want to make a subject access request, send an email to privacy@agate.one.

If we do hold information about you, you can ask us to correct any mistakes by, once again, sending an email to the above address.

 

  1. Review

We keep our privacy notice under regular review. This privacy notice was last updated on 24 May 2018.

 

  1. Contact

If you want to request information about our privacy policy you can email us at: privacy@agate.one.

 

 

Last updated 24-5-18